What Is Our Goal In The End

No matter the task, to be successful at that task you always need to keep in mind what exactly is your goal in the end. Henry Ford in his day, had a goal of making an automobile the average American could afford – to get there came the assembly line and the cost of manufacturing an auto was significantly reduced and his goal achieved. A famous watch manufacturing once had a goal of making a durable watch at a reasonable price that "takes a licking and keeps on ticking". In that era there were few that did not own a watch at some point made by that manufacturer.

These days it is unfortunate I think that folks don't really think about their own goals in the end. Their goal might only center around what everyone else is doing –thus versus distinctive Ford from Chevy, all cars look alike and the bulk of all TV shows are reality shows.

Now to compliance. While one does need to think of compliance in terms of keeping the regulators happy, that viewpoint could catch up with you if you fail to understand the "why" behind what you are doing. If you are only doing Risk Assessments because the regulators say you have to have them and that is what everyone else is doing, without update consideration, what are you accomplishing really other than hopefully making the regulators happy – and with that type of focus I doubt in the end you will? Those Risk Assessments should point out your compliance deficiencies and help you allocate your resources in terms of the focus of and timing of independent reviews and your internal training to achieve corrective action.

If your BSA Officer is doing a Suspicious Activity Report (SAR) because he or she knows it is required, but not understanding the concept of who is the subject of the SAR (it is the perpetrator, not the customer victim), has your BSA Officer really been trained to think about the purpose of a SAR?

If your CRA program as an Intermediate Small Bank, for example, does not involve outreach into your assessment area community for input, are you really accomplishing the intent of CRA? Does deposits from your assessment area provide resulting benefits to your assessment area in terms of needs regarding items such as qualifying loans?

If you have an ATR qualifying loan, and attempt to just show something in the file that you considered the regulatory factors without giving full consideration to all aspects of those factors that might affect repayment ability, that too could come back to bite you one day.

Thus, in compliance, just as in the goal of Henry Ford, the key to success is to fully think through and understand what is the goal in the end.